City of East Palo Alto - · PDF fileFY 2016-2017 Annual Report Permittee Name: City of East Palo Alto Table of Contents Section Page Section 1 – Permittee Information
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September 29, 2017
Mr. Bruce H. Wolfe Executive Officer
City of East Palo Alto Office of the City Manager
San Francisco Bay Regional Water Quality Control Board 1515 Clay Street, Suite 1400 Oakland, CA 94612
Subject: City of East Palo Alto FY 16/17 Annual report
Dear Mr. Wolfe,
This letter and Annual Report with attachments is submitted by The City of East Palo Alto pursuant to the Municipal Regional Stormwater NPDES Permit (MRP), Order No. R2-2015-0049, NPDES Permit No. CAS612008 issued by the San Francisco Bay
Regional Water Quality Control Board. This Annual ' Report provides documentation of compliance activities conducted during FY 16/17.
With the assistance of the Water Board, the City of East Palo Alto has identified defiCiencies and made updates to the FY 15/16 Enforcement Response Plan, and Business Inspection Plan, which resulted in fully integrating the inspection requirements into various City divisions in response to the Notice of Violation the City received.
The City has also made progress in Amending the Long Term Trash Load Reduction Plan, shifting from "trash capture equivalency measures" towards full trash capture device use as a consistent long term remedy. While the originally proposed large scale full trash capture concept may result in substantial life safety impacts, the City will continue to pursue imminent full trash capture device installation to meet our mandates, with full support from the City Council and we will continue to keep your team abreast as we pursue solutions that will meet the requirements while keeping our community safe.
The City remains vigilant on meeting MRP 2.0 mandates and will continue to update programs as needed for effective pollution prevention and compliance verification.
2415 University Ave. East Palo Alto, CA 94303
Phone: (650) 853-3100 Fax: (650) 853-3115
www.cityofepa.org cmoffice@cityofepa.org
Attachment:City of East Palo Alto FY 16/17 Annual report
Municipal Regional Permit National Pollution Discharge Elimination System
City of East Palo Alto
ANNUAL REPORT
Fiscal Year 2016-2017
July 1, 2016-June 30, 2017
FY 2016-2017 Annual Report Permittee Name: City of East Palo Alto
Table of Contents
Section Page
Section 1 – Permittee Information ................................................................................................................................. 1-1
Section 2 – Provision C.2 Municipal Operations ......................................................................................................... 2-1
Section 3 – Provision C.3 New Development and Redevelopment ....................................................................... 3-1
Section 4 – Provision C.4 Industrial and Commercial Site Controls ......................................................................... 4-1
Section 5 – Provision C.5 Illicit Discharge Detection and Elimination ..................................................................... 5-1
Section 6 – Provision C.6 Construction Site Controls .................................................................................................. 6-1
Section 7 – Provision C.7 Public Information and Outreach .................................................................................... 7-1
Section 9 – Provision C.9 Pesticides Toxicity Controls ................................................................................................ 9-1
Section 10 – Provision C.10 Trash Load Reduction ................................................................................................... 10-1
Section 11 – Provision C.11 Mercury Controls ........................................................................................................... 11-1
Section 12 – Provision C.12 PCBs Controls ................................................................................................................. 12-1
Section 13 – Provision C.13 Copper Controls ............................................................................................................ 13-1
Section 15 – Provision C.15 Exempted and Conditionally Exempted Discharges ............................................. 15-1
FY 2016 - 2017 Annual Report Permittee Information
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 1-1 9/30/17
Section 1 – Permittee Information Section 1 – Permittee Information
SECTION I. BACKGROUND INFORMATIONSECTION I. BACKGROUND INFORMATION
Background Information
Permittee Name: City of East Palo Alto
Population: 31,000
NPDES Permit No.: CAS612008
Order Number: R2-2015-0049
Reporting Time Period (month/year): July 1, 2016 through June 30, 2017
Name of the Responsible Authority: Kamal Fallaha Title: Public Works Director
Mailing Address: 1960 Tate Street
City: East Palo Alto Zip Code: CA County: 94025
Telephone Number: 650-853-3117 Fax Number: 650-853-3179
E-mail Address: kfallaha@cityofepa.org
Name of the Designated Stormwater
Management Program Contact (if
different from above):
Michelle Daher Title: Management Analyst: Environmental Programs
Department: Community and Economic Development
Mailing Address: 1960 Tate Street
City: East Palo Alto Zip Code: CA County: 94025
Telephone Number: 650-853-3197 Fax Number: 650-853-3179
E-mail Address: mdaher@cityofepa.org
FY 2016-2017 Annual Report C.2 – Municipal Operations
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 2-1 9/30/17
Section 2 - Provision C.2 Reporting Municipal Operations
Program Highlights and Evaluation Highlight/summarize activities for reporting year:
Summary:
During FY 16/17, the City has1) participated in SMCWPPP’s Municipal Maintenance Subcommittee; 2) prepared a full capture device assessment;
3) further developed the City’s O&M data management program including the adoption of the SMCWPPP Excel tracking template for maintenance
of the small trash capture basket type devices; and 3) adopted the SMCWPPP pesticide tracking Excel template for reporting pesticide data
management program for use in FY 2017/2018.
C.2.a. ► Street and Road Repair and Maintenance
Place a Y in the boxes next to activities where applicable BMPs were implemented. If not applicable, type NA in the box and provide an
explanation in the comments section below. Place an N in the boxes next to activities where applicable BMPs were not implemented for one or
more of these activities during the reporting fiscal year, then in the comments section below provide an explanation of when BMPs were not
implemented and the corrective actions taken.
Y Control of debris and waste materials during road and parking lot installation, repaving or repair maintenance activities from polluting
stormwater
Y Control of concrete slurry and wastewater, asphalt, pavement cutting, and other street and road maintenance materials and wastewater
from discharging to storm drains from work sites.
Y Sweeping and/or vacuuming and other dry methods to remove debris, concrete, or sediment residues from work sites upon completion of
work.
Comments:
C.2.b. ► Sidewalk/Plaza Maintenance and Pavement Washing
Place a Y in the boxes next to activities where applicable BMPs were implemented. If not applicable, type NA in the box and provide an
explanation in the comments section below. Place an N in the boxes next to activities where applicable BMPs were not implemented for one or
more of these activities during the reporting fiscal year, then in the comments section below provide an explanation of when BMPs were not
implemented and the corrective actions taken.
Y Control of wash water from pavement washing, mobile cleaning, pressure wash operations at parking lots, garages, trash areas, gas station
fueling areas, and sidewalk and plaza cleaning activities from polluting stormwater
Y Implementation of the BASMAA Mobile Surface Cleaner Program BMPs
FY 2016-2017 Annual Report C.2 – Municipal Operations
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 2-2 9/30/17
Comments:
C.2.c. ► Bridge and Structure Maintenance and Graffiti Removal
Place a Y in the boxes next to activities where applicable BMPs were implemented. If not applicable, type NA in the box and provide an
explanation in the comments section below. Place an N in the boxes next to activities where applicable BMPs were not implemented for one or
more of these activities during the reporting fiscal year, then in the comments section below provide an explanation of when BMPs were not
implemented and the corrective actions taken.
NA Control of discharges from bridge and structural maintenance activities directly over water or into storm drains
Y Control of discharges from graffiti removal activities
Y Proper disposal for wastes generated from bridge and structure maintenance and graffiti removal activities
Y Implementation of the BASMAA Mobile Surface Cleaner Program BMPs for graffiti removal
Y Employee training on proper capture and disposal methods for wastes generated from bridge and structural maintenance and graffiti
removal activities.
Y Contract specifications requiring proper capture and disposal methods for wastes generated from bridge and structural maintenance and
graffiti removal activities.
Comments:
FY 2016-2017 Annual Report C.2 – Municipal Operations
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 2-3 9/30/17
C.2.e. ► Rural Public Works Construction and Maintenance
Does your municipality own/maintain rural1 roads: Yes X No
If your answer is No then skip to C.2.f.
Place a Y in the boxes next to activities where applicable BMPs were implemented. If not applicable, type NA in the box and provide an
explanation in the comments section below. Place an N in the boxes next to activities where applicable BMPs were not implemented for one or
more of these activities during the reporting fiscal year, then in the comments section below provide an explanation of when BMPs were not
implemented and the corrective actions taken.
Control of road-related erosion and sediment transport from road design, construction, maintenance, and repairs in rural areas
Identification and prioritization of rural road maintenance based on soil erosion potential, slope steepness, and stream habitat resources
No impact to creek functions including migratory fish passage during construction of roads and culverts
Inspection of rural roads for structural integrity and prevention of impact on water quality
Maintenance of rural roads adjacent to streams and riparian habitat to reduce erosion, replace damaging shotgun culverts and excessive
erosion
Re-grading of unpaved rural roads to slope outward where consistent with road engineering safety standards, and installation of water bars
as appropriate
Inclusion of measures to reduce erosion, provide fish passage, and maintain natural stream geomorphology when replacing culverts or
design of new culverts or bridge crossings
Comments including listing increased maintenance in priority areas:
C.2.f. ► Corporation Yard BMP Implementation
Place an X in the boxes below that apply to your corporations yard(s):
We do not have a corporation yard
Our corporation yard is a filed NOI facility and regulated by the California State Industrial Stormwater NPDES General Permit
Y We have a Stormwater Pollution Prevention Plan (SWPPP) for the Corporation Yard(s)
1Rural means any watershed or portion thereof that is developed with large lot home-sites, such as one acre or larger, or with primarily agricultural, grazing or open
space uses.
FY 2016-2017 Annual Report C.2 – Municipal Operations
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 2-4 9/30/17
Place an X in the boxes below next to implemented SWPPP BMPs to indicate that these BMPs were implemented in applicable instances.If not
applicable, type NA in the box. If one or more of the BMPs were not adequately implemented during the reporting fiscal year then indicate so and
explain in the comments section below:
Y Control of pollutant discharges to storm drains such as wash waters from cleaning vehicles and equipment
Y Routine inspection prior to the rainy seasons of corporation yard(s) to ensure non-stormwater discharges have not entered the storm drain
system
Y Containment of all vehicle and equipment wash areas through plumbing to sanitary or another collection method
Y Use of dry cleanup methods when cleaning debris and spills from corporation yard(s) or collection of all wash water and disposing of wash
water to sanitary or other location where it does not impact surface or groundwater when wet cleanup methods are used
Y Cover and/or berm outdoor storage areas containing waste pollutants
Comments:
If you have a corporation yard(s) that is not an NOI facility, complete the following table for inspection results for your corporation yard(s) or attach
a summary including the following information:
Corporation Yard Name
Corp Yard Activities w/ site-
specific SWPPP BMPs
Inspection
Date2 Inspection Findings/Results
Date and Description of
Follow-up and/or Corrective
Actions
City of East Palo Alto
Corporation Yard
150 Tara Road
East Palo Alto, CA
HHW Collection with covered
secondary containment,
Illegal Dumping Collection
with covered bins,
Stormdrain Vacuum
Collection with three
chamber interceptor and
stormdrain inlet protection,
Stockpiles for park and
median maintenance
covered, vehicle storage
with fluid management
10/04/2016 Develop long term HHW disposal plan for
pickup of illegal dumping;
Ensure all HW has secondary containment
in a covered area;
Move HW materials from outdoors to
covered area;
Obtain pesticide training prior to pesticide
applications;
Ensure all non-op vehicles have fluid
containment under chassis
Contract for ongoing HHW
collection is still a long term
need—RFP is imminent; HHW
materials were picked up
from contractor
See #1 above
Completed same day
Completed prior to pesticide
use
Completed same day
2 Minimum inspection frequency is once a year during September.
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 2-5 9/30/17
Section 3 - Provision C.3 Reporting New Development and Redevelopment
C.3.b.iv.(1) ► Regulated Projects Approved Prior to C.3 Requirements
(For FY 2016-17 Annual Report only) Does your agency have any Regulated Projects
that were approved with no Provision C.3 stormwater treatment requirements under a
previous MS4 permit and that did not begin construction by January 1, 2016 (i.e., that
are subject to Provision C.3.b.i.(2))?
Yes
X
No
If yes, complete attached Table C.3.b.iv.(1).
C.3.b.iv.(2) ► Regulated Projects Reporting
Fill in attached table C.3.b.iv.(2) or attach your own table including the same information.
C.3.e.iv. ► Alternative or In-Lieu Compliance with Provision C.3.c.
Is your agency choosing to require 100% LID treatment onsite for all Regulated Projects
and not allow alternative compliance under Provision C.3.e.?
Yes X
No
Comments (optional):
C.3.e.v. ► Special Projects Reporting
1. In FY 2016-17, has your agency received, but not yet granted final discretionary
approval of, a development permit application for a project that has been identified as
a potential Special Project based on criteria listed in MRP Provision C.3.e.ii.(2) for any of
the three categories of Special Projects (Categories A, B or C)?
Yes
X
No
2. In FY 2016-17, has your agency granted final discretionary approval to a Special
Project? If yes, include the project in both the C.3.b.iv.(2) Table, and the C.3.e.v. Table.
Yes X
No
If you answered “Yes” to either question,
1) Complete Table C.3.e.v.
2) Attach narrative discussion of 100% LID Feasibility or Infeasibility for each project.
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 2-6 9/30/17
C.3.h.v.(2) ► Reporting Newly Installed Stormwater Treatment Systems and HM Controls (Optional)
On an annual basis, before the wet season, provide a list of newly installed (installed within the reporting year) stormwater treatment systems and
HM controls to the local mosquito and vector control agency and the Water Board. The list shall include the facility locations and a description of
the stormwater treatment measures and HM controls installed.
See attached table.
C.3.h.v.(3)(a)–(c) and (f) ► Installed Stormwater Treatment Systems Operation and
Maintenance Verification Inspection Program Reporting
Site Inspections Data Number/Percentage
Total number of Regulated Projects (including offsite projects, and Regional Projects) in your agency’s database
or tabular format at the end of the previous fiscal year (FY15-16)
12
Total number of Regulated Projects (including offsite projects, and Regional Projects) in your agency’s database
or tabular format at the end of the reporting period (FY 16-17)
14
Total number of Regulated Projects (including offsite projects, and Regional Projects) for which O&M verification
inspections were conducted during the reporting period (FY 16-17)
6
Percentage of the total number of Regulated Projects (including offsite projects, and Regional Projects) inspected
during the reporting period (FY 16-17)
43%
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 2-7 9/30/17
C.3.h.v.(3)(d)-(e) ► Installed Stormwater Treatment Systems Operation and Maintenance Verification
Inspection Program Reporting
Provide a discussion of the inspection findings for the year and any common problems encountered with various types of treatment systems
and/or HM controls. This discussion should include a general comparison to the inspection findings from the previous year.
Summary:
The City requires certified 3rd party inspection of vaults within the jurisdiction.
All vegetated stormwater treatment facilities are inspected in-house according to the Enforcement Response Plan at MRP required frequency.
Provide a discussion of the effectiveness of the O&M Program and any proposed changes to improve the O&M Program (e.g., changes in
prioritization plan or frequency of O&M inspections, other changes to improve effectiveness program).
Summary:
Vegetated features have been noted as requiring replacement in several locations with one specific location requiring replacement of the entire
irrigation system which was non-functional resulting in complete plant replacement.
C.3.h.v.(4) ► Enforcement Response Plan
(For FY 2016-17 Annual Report only) Has your agency completed an Enforcement
Response Plan for all O&M inspections of stormwater treatment measures by July 1,
2017?
X
Yes
No
If No, provide schedule for completion:
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 2-8 9/30/17
C.3.i. ► Required Site Design Measures for Small Projects and Detached Single Family Home Projects
On an annual basis, discuss the implementation of the requirements of Provision C.3.i, including ordinance revisions, permit conditions,
development of standard specifications and/or guidance materials, and staff training.
Summary:
BASMAA prepared standard specifications in four fact sheets regarding the site design measures listed in Provision C.3.i, as a resource for
Permittees. We have modified local ordinances/policies/procedures and forms/checklists to require all applicable projects approved after
December 1, 2012 to implement at least one of the site design measures listed in Provision C.3.i.
C.3.j.i.(5)(a) ► Green Infrastructure Framework or Work Plan
(For FY 2016-17 Annual Report only) Was your agency’s Green Infrastructure
Framework or Work Plan approved by the agency’s governing body, mayor, city
manager, or county manager by June 30, 2017?
X
Yes, approval
documentation
attached
No
If Yes, describe approval process and documentation: The Green Infrastructure Framework/Work Plan has been completed and adopted by the
City Manager with the Green Infrastructure Plan included by City Council adopted and funded Capital Improvement Plan for a project to be
initiated during Fiscal Year 2017/2018 included with funding for a consultant to assist the City in finalizing this project. The CIP is available at the
following link: http://www.ci.east-palo-alto.ca.us/DocumentCenter/View/2736
If No, provide schedule for completion:
C.3.j.i.(5)(d) ► Green Infrastructure Outreach
On an annual basis, provide a summary of your agency’s outreach and education efforts pertaining to Green Infrastructure planning and
implementation.
Summary:
The City has conducted outreach to the City Council regarding the upcoming changes as the City plans to shift from grey to green infrastructure
for stormwater conveyance. City staff has attended training, including the City’s engineering division, they City’s planning division, the Public
works Director, the City Engineer and the City Manager.
Conditions of Approval for the Ravenswood Business District also include requirements for Green Infrastructure as the City begins development
efforts in this northern segment of the City where stormdrains are ill designed or non-existent. As project concepts come into the City for preview,
the City has been informing developers that these requirements will be forthcoming, and requiring voluntary compliance with finding solutions
prior to the submittal of development proposals.
Please refer to the SMCWPPP FY 16-17 Annual Report for a summary of outreach efforts implemented.
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 2-9 9/30/17
C.3.j.ii.(2) ► Early Implementation of Green Infrastructure Projects
On an annual basis, submit a list of green infrastructure projects, public and private, that are already planned for implementation during the permit
term and infrastructure projects planned for implementation during the permit term that have potential for green infrastructure measures. Include
the following information:
A summary of planning or implementation status for each public and private green infrastructure project that is not also a Regulated
Project as defined in Provision C.3.b.ii. (see C.3.j.ii.(2) Table B - Planned Green Infrastructure Projects).
A summary of how each public infrastructure project with green infrastructure potential will include green infrastructure measures to the
maximum extent practicable during the permit term. For any public infrastructure project where implementation of green infrastructure
measures is not practicable, submit a brief description of the project and the reasons green infrastructure measures were impracticable to
implement (see C.3.j.ii.(2) Table A - Public Projects Reviewed for Green Infrastructure).
Background Information:
Describe how this provision is being implemented by your agency, including the process used by your agency to identify projects with potential for
green infrastructure, if applicable.
Through the plan review process, conditions of approval are placed on projects over an acre in size to require, in addition to low impact
development requirements, that the project proponent works with the City to identify the potential for green infrastructure along the public right of
way to treat street and sidewalk runoff with treatment measures consistent with the BASMAA guidance. Projects, where feasible, integrate GI
components into the project with design details consistent with City approval. Upon completion, the City will provide maintenance on these
facilities for the life of the system.
Summary of Planning or Implementation Status of Identified Projects:
The City has several development projects that are in the pre-submittal phase, all of which have been informed that a Green Infrastructure review
will be required prior to design approval. As of this time, none of these projects have submitted a formal application, and will likely be reported on
in FY 17/18 if formal applications have been submitted. The City intends to offer a menu of options for public right of way green infrastructure
alternatives.
C.3.j.iii.(2) ► Participate in Processes to Promote Green Infrastructure
On an annual basis, report on the goals and outcomes during the reporting year of work undertaken to participate in processes to promote green
infrastructure.
Please refer to the SMCWPPP FY 16-17 Annual Report for a summary of efforts conducted to help regional, State, and federal agencies plan, design
and fund incorporation of green infrastructure measures into local infrastructure projects, including transportation projects.
C.3.j.iv.(2) ► Tracking and Reporting Progress
On an annual basis, report progress on development and implementation of methods to track and report implementation of green infrastructure
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 2-10 9/30/17
measures and provide reasonable assurance that wasteload allocations for TMDLs are being met.
Please refer to the SMCWPPP FY 16-17 Annual Report for a summary of methods being developed to track and report implementation of green
infrastructure measures.
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 2-11 9/30/17
C.3.b.iv.(1) ► List of Regulated Projects Approved Prior to C.3
Requirements
Project Name
Project No.
Project Location3, Street Address Type of Stormwater Treatment
Required4
Type of Exemption Granted5
None to Report None to Report None to Report None to Report
3 Include cross streets 4 Indicate the stormwater treatment system required, if applicable 5 Indicate the type for exemption, if applicable. For example, the project was previously approved with a vesting tentative map, or the Permittee has no legal authority to require
changes to previously granted approvals (such as previously granted building permits).
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 3-12 9/30/16
C.3.b.iv.(2) ► Regulated Projects Reporting Table (part 1) –
Projects Approved During the Fiscal Year Reporting Period
Project Name
Project No.
Project Location6, Street
Address Name of Developer
Project
Phase
No.7
Project Type &
Description8 Project Watershed9
Total
Site
Area
(Acres)
Total
Area of
Land
Disturbed
(Acres)
Total New
Impervious
Surface
Area (ft2)10
Total
Replaced
Impervious
Surface Area
(ft2)11
Total Pre-
Project
Impervious
Surface
Area12(ft2)
Total Post-
Project
Impervious
Surface
Area13(ft2)
Private Projects
None to Report None to Report None to Report None to
Report None to Report None to Report None
to
Report
None to
Report None to
Report None to
Report None to
Report None to
Report
Public Projects
None to Report None to Report None to Report None to
Report None to Report None to Report None
to
Report
None to
Report None to
Report None to
Report None to
Report None to
Report
Comments:
During FY 16/17 the City had an ongoing water moratorium which precluded any new development that would require additional water meters or enhanced water lines. As such, no new projects have been
approved. It is anticipated that development will resume during the second half of FY 17/18.
No regulated public projects were approved during this Fiscal Year.
6Include cross streets 7If a project is being constructed in phases, indicate the phase number and use a separate row entry for each phase. If not, enter “NA”. 8Project Type is the type of development (i.e., new and/or redevelopment). Example descriptions of development are: 5-story office building, residential with 160 single-family homes with five 4-story buildings to contain 200 condominiums,
100 unit 2-story shopping mall, mixed use retail and residential development (apartments), industrial warehouse. 9State the watershed(s) in which the Regulated Project is located. Downstream watershed(s) may be included, but this is optional. 10All impervious surfaces added to any area of the site that was previously existing pervious surface. 11All impervious surfaces added to any area of the site that was previously existing impervious surface. 12For redevelopment projects, state the pre-project impervious surface area. 13For redevelopment projects, state the post-project impervious surface area.
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 3-13 9/30/16
C.3.b.iv.(2) ► Regulated Projects Reporting Table (part 2) –
Projects Approved During the Fiscal Year Reporting Period
(private projects)
Project Name
Project No.
Application Deemed Complete
Date14
Application
Final Approval
Date15
Source
Control
Measures16
Site Design
Measures17
Treatment Systems
Approved18
Type of Operation
& Maintenance
Responsibility
Mechanism19
Hydraulic
Sizing
Criteria20
Alternative
Compliance
Measures21/22
Alternative
Certification23
HM
Controls24/25
Private Projects
None to Report None to Report None to Report None to
Report None to
Report None to Report None to Report None to
Report None to
Report None to
Report None to
Report
14For private projects, state project application deemed complete date. If the project did not go through discretionary review, report the building permit issuance date. 15For private projects, state project application final discretionary approval date. If the project did not go through discretionary review, report the building permit issuance date. 16List source control measures approved for the project. Examples include: properly designed trash storage areas; storm drain stenciling or signage; efficient landscape irrigation systems; etc. 17List site design measures approved for the project. Examples include: minimize impervious surfaces; conserve natural areas, including existing trees or other vegetation, and soils; construct sidewalks, walkways, and/or patios with
permeable surfaces, etc. 18List all approved stormwater treatment system(s) to be installed onsite or at a joint stormwater treatment facility (e.g., flow through planter, bioretention facility, infiltration basin, etc.). 19List the legal mechanism(s) (e.g., O&M agreement with private landowner; O&M agreement with homeowners’ association; O&M by public entity, etc…) that have been or will be used to assign responsibility for the maintenance of the
post-construction stormwater treatment systems. 20See Provision C.3.d.i. “Numeric Sizing Criteria for Stormwater Treatment Systems” for list of hydraulic sizing design criteria. Enter the corresponding provision number of the appropriate criterion (i.e., 1.a., 1.b., 2.a., 2.b., 2.c., or 3). 21For Alternative Compliance at an offsite location in accordance with Provision C.3.e.i.(1), on a separate page, give a discussion of the alternative compliance site including the information specified in Provision C.3.b.v.(1)(m)(i) for the
offsite project. 22For Alternative Compliance by paying in-lieu fees in accordance with Provision C.3.e.i.(2), on a separate page, provide the information specified in Provision C.3.b.v.(1)(m)(ii) for the Regional Project. 23Note whether a third party was used to certify the project design complies with Provision C.3.d. 24If HM control is not required, state why not. 25If HM control is required, state control method used (e.g., method to design and size device(s) or method(s) used to meet the HM Standard, and description of device(s) or method(s) used, such as detention basin(s), biodetention unit(s),
regional detention basin, or in-stream control).
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 3-14 9/30/16
C.3.b.iv.(2) ► Regulated Projects Reporting Table (part 2) –
Projects Approved During the Fiscal Year Reporting Period
(public projects)
Project
Name
Project
No.
Approval
Date26
Date Construction
Scheduled to Begin
Source Control
Measures27
Site Design
Measures28
Treatment Systems
Approved29
Operation & Maintenance
Responsibility Mechanism30
Hydraulic
Sizing Criteria31
Alternative
Compliance
Measures32/33
Alternative
Certification34
HM
Controls35/36
Public Projects
None to
Report None to
Report None to Report None to Report None to
Report None to Report None to Report None to
Report None to Report None to Report None to
Report
Comments:
During FY 16/17 the City had an ongoing water moratorium which precluded any new development that would require additional water meters or enhanced water lines. As such, no new projects have been
approved. It is anticipated that development will resume during the second half of FY 17/18.
26For public projects, enter the plans and specifications approval date. 27List source control measures approved for the project. Examples include: properly designed trash storage areas; storm drain stenciling or signage; efficient landscape irrigation systems; etc. 28List site design measures approved for the project. Examples include: minimize impervious surfaces; conserve natural areas, including existing trees or other vegetation, and soils; construct sidewalks, walkways, and/or patios with
permeable surfaces, etc. 29List all approved stormwater treatment system(s) to be installed onsite or at a joint stormwater treatment facility (e.g., flow through planter, bioretention facility, infiltration basin, etc.). 30List the legal mechanism(s) (e.g., maintenance plan for O&M by public entity, etc…) that have been or will be used to assign responsibility for the maintenance of the post-construction stormwater treatment systems. 31See Provision C.3.d.i. “Numeric Sizing Criteria for Stormwater Treatment Systems” for list of hydraulic sizing design criteria. Enter the corresponding provision number of the appropriate criterion (i.e., 1.a., 1.b., 2.a., 2.b., 2.c., or 3). 32For Alternative Compliance at an offsite location in accordance with Provision C.3.e.i.(1), on a separate page, give a discussion of the alternative compliance site including the information specified in Provision C.3.b.v.(1)(m)(i) for the
offsite project. 33For Alternative Compliance by paying in-lieu fees in accordance with Provision C.3.e.i.(2), on a separate page, provide the information specified in Provision C.3.b.v.(1)(m)(ii) for the Regional Project. 34Note whether a third party was used to certify the project design complies with Provision C.3.d. 35If HM control is not required, state why not. 36If HM control is required, state control method used (e.g., method to design and size device(s) or method(s) used to meet the HM Standard, and description of device(s) or method(s) used, such as detention basin(s), biodetention unit(s),
regional detention basin, or in-stream control).
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 3-15 9/30/17
C.3.h.v.(2) ► Table of Newly Installed37 Stormwater Treatment Systems and
Hydromodification Management (HM) Controls (Optional)
Fill in table below or attach your own table including the same information.
Name of Facility Address of Facility
Party Responsible38
For Maintenance
Type of Treatment/HM
Control(s)
Senior Housing Mid Peninsula
2358 Univerity Ave
Mid Penn Housing
Bioretention
Cavallino Collision/ Fix It Auto
1874/1880/1884? W Bayshore Rd
Ric Donofrio
Treatment Trench
(previously installed in
2008, without O&M
Agreement)
Sobrato
2100 University Ave Sobrato Organization Flow Through Planters
37
“Newly Installed” includes those facilities for which the final installation inspection was performed during this reporting year. 38
State the responsible operator for installed stormwater treatment systems and HM controls.
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 3-16 9/30/17
C.3.e.v. ► Special Projects Reporting Table
Reporting Period – July 1 2016 - June 30, 2017
Project
Name & No.
Permittee Address Application
Submittal
Date39
Status40 Description41 Site Total
Acreage
Gross
Density
DU/Acre
Density
FAR
Special
Project
Category42
LID
Treatment
Reduction
Credit
Available43
List of LID
Stormwater
Treatment
Systems44
List of Non-
LID
Stormwater
Treatment
Systems45
None to
Report None to
Report None to
Report None to
Report None to
Report None to
Report None to
Report None to
Report None
to
Report
None to
Report None to
Report None to
Report None to
Report
39
Date that a planning application for the Special Project was submitted. 40 Indicate whether final discretionary approval is still pending or has been granted, and provide the date or version of the project plans upon which reporting is based. 41Type of project (commercial, mixed-use, residential), number of floors, number of units, type of parking, and other relevant information. 42 For each applicable Special Project Category, list the specific criteria applied to determine applicability. For each non-applicable Special Project Category, indicate n/a. 43For each applicable Special Project Category, state the maximum total LID Treatment Reduction Credit available. For Category C Special Projects also list the individual
Location, Density, and Minimized Surface Parking Credits available. 44: List all LID stormwater treatment systems proposed. For each type, indicate the percentage of the total amount of runoff identified in Provision C.3.d. for the Special Project’s
drainage area. 45List all non-LID stormwater treatment systems proposed. For each type of non-LID treatment system, indicate: (1) the percentage of the total amount of runoff identified in
Provision C.3.d. for the Special Project's drainage area, and (2) whether the treatment system either meets minimum design criteria published by a government agency or
received certification issued by a government agency, and reference the applicable criteria or certification.
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 3-17 9/30/17
Special Projects Narrative
Nothing to report: no Special Projects were approved or installed in this jurisdiction within the MRP permit term(s).
FY 2016-2017 Annual Report C.3 – New Development and Redevelopment
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 3-18 9/30/17
C.3.j.ii.(2) ► Table A - Public Projects Reviewed for Green
Infrastructure
Project Name and
Location46
Project Description Status47 GI
Included?48
Description of GI Measures
Considered and/or Proposed
or Why GI is Impracticable to Implement49
Bay Road Roadway replacement from
below the gravel sub-base.
Design Review: 95%
drawings
Partial Proposed to include tree well filters on portions
of the project, where practicable.
C.3.j.ii.(2) ► Table B - Planned and/or Completed Green
Infrastructure Projects
Project Name and
Location50
Project Description Planning or
Implementation Status
Green Infrastructure Measures Included
Bay Road Roadway replacement from
below the gravel sub-base.
Design Review: 95%
drawings
Proposed to include tree well filters on portions of the
project, where practicable. Funding only available for
a portion of the project. Still being determined how this
project will phase.
46 List each public project that is going through your agency’s process for identifying projects with green infrastructure potential. 47 Indicate status of project, such as: beginning design, under design (or X% design), projected completion date, completed final design date, etc. 48 Enter “Yes” if project will include GI measures, “No” if GI measures are impracticable to implement, or “TBD” if this has not yet been determined. 49 Provide a summary of how each public infrastructure project with green infrastructure potential will include green infrastructure measures to the maximum extent
practicable during the permit term. If review of the project indicates that implementation of green infrastructure measures is not practicable, provide the reasons
why green infrastructure measures are impracticable to implement. 50 List each planned (and expected to be funded) public and private green infrastructure project that is not also a Regulated Project as defined in Provision C.3.b.ii.
Note that funding for green infrastructure components may be anticipated but is not guaranteed to be available or sufficient.
FY 2016-2017 Annual Report C.5 – Illicit Discharge Detection and Elimination
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 5-1 9/30/17
Section 4 – Provision C.4 Industrial and Commercial Site Controls
Program Highlights and Evaluation Highlight/summarize activities for reporting year:
Summary:
During FY 16/17, the City has 1) updated our business plans, facilities lists, and inspection frequencies and priorities; 2) conducting inspections; 3)
conducting training, 4) participating in the Program’s CII Subcommittee, and 5) updated our Enforcement Response Plan, which applies to
Commercial and Industrial inspection activities, among all inspections pertinent to MRP compliance. Refer to the C.4 Industrial and Commercial
Site Controls section of the SMCWPPP FY 16-17 Annual Report for a description of Program activities. Further, the City has entirely revised the
inspection program to include Enforcement personnel that are able to readily escalate enforcement as needed and track inspections, now
integrated into the Code Enforcement program.
In response to the Regional Water Board’s January 30, 2017 C.4 and C.5 Compliance Letter the City of East Palo Alto: 1) participated in February
15, 2017 meeting to discuss responses, 2) reviewed and approved April 28, 2017 response letter to RWB, 3) updating the City’s ERP by June 30th to
include the City’s responsibility for all stormwater compliance with all MRP requirements, 4) updated the City’s BIP by July 30th, including
requirements set forth in the Notice of Violation received by the Water Board in the May 2017 notice 5) participated in the April 25, 2017 working
meeting to update revised BIP/ERP SMCWPPP Templates, and 6) continued to review City business licenses, Google Earth and field inspected to
identify businesses not inspected by County Environmental Health (CEH) inspectors but inspected by City staff.
C.4.b.iii. ► Potential Facilities List
List below or attach your list of industrial and commercial facilities in your Inspection Plan to inspect that could reasonably be considered to cause
or contribute to pollution of stormwater runoff.
The City currently has a San Mateo County Environmental Health (CEH) agreement to perform stormwater inspections. The City has previously
supplemented CEH’s list of facilities, with non-retail food and non-hazmat facilities located in East Palo Alto deemed to merit stormwater
inspections. The City’s updated ERP indicates that the City will become fully responsible for all MRP related inspections beginning FY 17/18.
However, upon receipt of the Notice of Violation pertaining to roles and responsibilities and tracking of business inspections, and to ensure
stormwater compliance with FY 16/17, the City has conducted stormwater inspections for all businesses that require stormwater inspections in
which case SMCEH has reported on some businesses that the City also inspected during FY 16/17, but the City will only report on inspections
conducted by City staff for FY 16/17 and going forward.
FY 2016-2017 Annual Report C.5 – Illicit Discharge Detection and Elimination
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 5-2 9/30/17
C.4.d.iii.(2)(a) & (c) ► Facility Inspections
Fill out the following table or attach a summary of the following information. Indicate your reporting methodology below.
Permittee reports multiple discrete potential and actual discharges as one enforcement action.
Permittee reports the total number of discrete potential and actual discharges on each site.
Number Percent
Total number of inspections conducted (C.4.d.iii.(2)(a)) 33
Number of enforcement actions or discreet number of potential and actual discharges 16
Violations Enforcement actions or discreet number of potential and actual discharges resolved within 10
working days or otherwise deemed resolved in a longer but still timely manner (C.4.d.iii.(2)(c))
15 94%
Comments:
There has been a single enforcement action that remains unresolved. This matter pertains to one automotive site that had continuously been
washing vehicles outdoors. Site has a treatment trench since 2008, and the final resolution requires O&M Agreement to be recorded for the site.
There are some concerns about address/APN/legal description of property being in agreement. Once this is resolved, site is in compliance. No
discharge is ongoing. The City is no longer reporting on SMCEH inspections and has already started overlapping inspections with CEH beginning
2016/2017 and will continue to conduct inspections in the future without reporting SMCEH inspection.
C.4.d.iii.(2)(b) ► Frequency and Type of Enforcement
Conducted
Fill out the following table or attach a summary of the following information.
Enforcement Action
(as listed in ERP)51
Number of Enforcement Actions Taken
Level 1 Verbal Warning / Written Notice/Minor Violation—Return to Compliance 10
Level 2 Warning Notice or Administrative Action or Stop Work Notice 6
Level 3 Administrative Action with Penalty and/or Cost Recovery 0
Level 4 Legal Action 0
Total 16
51Agencies to list specific enforcement actions as defined in their ERPs.
FY 2016-2017 Annual Report C.5 – Illicit Discharge Detection and Elimination
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 5-3 9/30/17
C.4.d.iii.(2)(d) ► Frequency of Potential and Actual Non-stormwater Discharges by Business
Category
Fill out the following table or attach a summary of the following information.
Business Category52
Number of Actual
Discharges
Number of Potential
Discharges
Automotive (may be home based) 0 0%
Mobile Business/Home Based (not automotive) 0 0%
Light Industrial 1 3%
Food, Health, Restaurant or Market 0 0%
C.4.d.iii.(2)(e) ► Non-Filers
List below or attach a list of the facilities required to have coverage under the Industrial General Permit but have not filed for coverage:
C.4.e.iii. ►Staff Training Summary
Training Name
Training
Dates Topics Covered
No. of
Industrial/
Commercial
Site
Inspectors in
Attendance
Percent of
Industrial/
Commercial
Site
Inspectors in
Attendance
No. of IDDE
Inspectors
in
Attendance
Percent of
IDDE
Inspectors
in
Attendance
ERP and BIP Training
9/12/2016 11/8/2016 2/6/2017 5/5/2017 6/20/2017
Enforcement Response Plan and Business Inspection Plan, pre and post-annual inspections, topics that are related to enforcement procedures, NOV, and updates to both documents.
4 100 4 100
Automotive Inspections
10/10/2016 3/29/2017 4/21/2017 6/12/2017
Various case studies for automotive facilities from repair shops to retail shops—ensuring no stormwater pollution potential.
4 100 4 100
All CII Inspection
1/23/2016 6/19/2017
Various topics that the code enforcement and inspection officer for public works request, along with code enforcement meetings.
4 100 4 100
52List your Program’s standard business categories.
FY 2016-2017 Annual Report C.5 – Illicit Discharge Detection and Elimination
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 5-4 9/30/17
Comments:These reported trainings were all conducted in-house. Staff also attended SMCWPPP training opportunities and National SWPPP training.
After all training, at the end of the year, two of the three officers trained are moving on to other juriscitions and we will have one of the 3 trained CE
officers remaining. Our public works inspector will also remain, for a 50% retention rate.
Section 5 – Provision C.5 Illicit Discharge Detection and Elimination
Program Highlights and Evaluation Highlight/summarize activities for reporting year:
Provide background information, highlights, trends, etc.
Summary:
In FY 2016/2017, the City participated in the SMCWPPP CII Subcommittee. Generally the primary illicit discharges that were observed had to do
with illegal dumping of solid and human waste, as reported herein. Residents call any number in the City and each call is directed to our front
desk for appropriate call direction to the appropriate person. This system will be revised in FY17/18 as a new program for illicit discharge and
detection will be implemented to coincide with updated solid waste management programs, based on a new Clean City Plan going to City
Council on October 3, 2017 for consideration, and funded on May 23, 2017.
Refer to the C.5 Illicit Discharge Detection and Elimination section of the SMCWPPP FY 16-17 Annual Report for description of activities at the
countywide or regional level.
C.5.c.iii. ► Complaint and Spill Response Phone Number
Summary of any changes made during FY 16-17:
All calls are directed to our main line at 650-853-3185 during regular office hours. If the incident is an emergency, calls go to 9-1-1 (for a crime in
progress) or requires referral to Police Dispatch, calls are directed to the 650-321-1112 non-emergency dispatch.
C.5.d.iii.(1)-(3) ► Spill and Discharge Complaint Tracking
Spill and Discharge Complaint Tracking (fill out the following table or include an attachment of the following information)
Number Percentage
Discharges reported (C.5.d.iii.(1)) 12
Discharges reaching storm drains and/or receiving waters (C.5.d.iii.(2)) 0
Discharges resolved in a timely manner (C.5.d.iii.(3)) 12 100
Comments:
These items represent mostly illegally dumped hazardous waste and concrete that residents of staff report. In times where photos are taken, there
is not enough evidence considered for prosecution. Already in FY 17/18, we are receiving substantial complaints pertaining to human waste due
to no sanitary services around homeless encampments and on streets where RVs are present. This matter is being addressed through a potential
ordinance which will restrict oversized vehicles from parking along residential zones or within 500 feet of a residential zone. Oversized vehicles are
considered vehicles over 6 feet in height. This type of ordinance, if adopted, will address a majority of the City where parking is permitted. The City
FY 2016-2017 Annual Report C.5 – Illicit Discharge Detection and Elimination
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 5-5 9/30/17
is also considering regulating illegal dumping more strictly in general, by enacting ordinances that will enable more local enforcement on illegal
dumping from motor vehicles.
C.5.e.iii.(1) ► Control of Mobile Sources
(a) Provide your agency’s minimum standards and BMPs for various types of mobile businesses (C.5.e.iii.(1)(a))
The City of East Palo Alto follows the minimum standards and BMPs described in the “Mobile Businesses - Best Management Practices” brochure
developed by the SMCWPPP CII Subcommittee in in March 2015 for the following mobile business categories: automobile washers/detailers,
power washers, carpet cleaners, steam cleaners, pet care services. The BMP brochure is included in the Program Annual Report.
The City also works with businesses seeking business licenses to become a BASMAA Recognized Mobile Cleaner and follow the BASMAA BMPs
available on the website: http://basmaa.org/Training . In the event that a mobile business has been noted as a violator, the City is considering
having training be an incentive for lessened fees or fines in the future.
(b) Provide your agency’s enforcement strategy for mobile businesses (C.5.e.iii.(1)(b))
The City receives complaints from the public or during routine field work and will issue enforcement actions and track the activity through the
business inspection program.
Illicit Discharge Detection and Elimination (IDDE) spill and discharge complaint tracking system according to MRP C.5.d. is reserved for
individuals without businesses, who are conducting activities outside of the MRP compliance, or instances when an offending business cannot be
identified for responsibility.
Enforcement actions stormwater inspectors may take are detailed in our Enforcement Response Plan (ERP). Due to the unique nature of mobile
businesses it can be difficult to track enforcement of a single business across jurisdictions. The current strategy is for agencies to share
information on mobile business enforcement actions with the SMCWPPP CII Subcommittee facilitator. The Subcommittee facilitator periodically
updates the Mobile Business Enforcement Information table that resides on the members only section of the Program’s website (flowstobay.org).
(c) Provide a list and summary of the specific outreach events and education conducted by your agency to the different types of mobile
businesses operating within your jurisdiction (C.5.e.iii.(1)(c))
The Program developed a regional inventory of mobile businesses in the standard BMP categories listed in the “Mobile Businesses – Best
Management Practices” brochure. The BMP brochure and a transmittal letter were mailed to the business. The Mobile Cleaner Businesses BMP
brochure is posted on the SMCWPPP website. The CII Subcommittee also worked with the PIP Subcommittee to send outreach messages through
social media. These activities are discussed in the SMCWPPP FY16-17 Annual Report.
FY 2016-2017 Annual Report C.5 – Illicit Discharge Detection and Elimination
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 5-6 9/30/17
(d) Provide number of inspections conducted at mobile businesses and/or job sites in 2016-2017
(C.5.e.iii.(1)(d):
4
(e) Discuss enforcement actions taken against mobile businesses in 2016-2017 (C.5.e.iii.(1)(e))
Enforcement actions are typically taken in response to a complaint or illicit discharge through our IDDE Program or business inspection
program. Enforcement actions are tracked in the city’s regular code enforcement database under Code Enforcement (CE) prefix. required
by MRP C.5.d.ii and also double tracked through our Business Inspection Program. There were no enforcement activities taken against
mobile businesses this year. All businesses are also reported under our business inspection program (double reported).
(f) List below or attach the list of mobile businesses operating within your agency’s jurisdiction (C.5.e.iii.(1)(f))
In FY16-17 the CII Subcommittee requested the Program compile a regional inventory of mobile businesses located in San Mateo County.
The inventory was developed from individual city lists and internet searches of Google, Yelp! and yellow pages. The inventory includes
automotive washing, steam cleaning and carpet cleaning mobile businesses. The inventory will be periodically updated with mobile
businesses stormwater inspectors observe during routine field activities. The inventory is available to all Co-permittees on the members only
webpage of the SMCWPPP website. The inventory is included in the SMCWPPP FY16-17 Annual Report.
(g) Provide a list and summary of the county-wide or regional activities conducted, including sharing of mobile business inventories, BMP
requirements, enforcement action information, and education (C.5.e.iii.(1)(g))
Refer to the C.5 Illicit Discharge Detection and Elimination section of the SMCWPPP FY 16-17 Annual Report for description of activities at the
countywide or regional level.
FY 2016-2017 Annual Report C.6 – Construction Site Controls
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 6-1 9/30/17
Section 6 – Provision C.6 Construction Site Controls
C.6.e.iii.(3)(a)-(d) ► Site/Inspection Totals
Number of active Hillside
Sites (sites disturbing < 1
acre of soil requiring storm
water runoff quality
inspection) (C.6.e.iii.(3)(a))
Number of High Priority
Sites (sites disturbing < 1
acre of soil requiring storm
water runoff quality
inspection)
(C.6.e.iii..(3)(c))
Number of sites disturbing ≥ 1 acre
of soil
(C.6.e.iii.(3)(b))
Total number of storm water runoff quality
inspections conducted (include only Hillside Sites,
High Priority Sites and sites disturbing 1 acre or
more)
(C.6.e.iii.(3)(d))
#
0
#
1
#
1
#
8
Comments:
1) The City conducted monthly (at a minimum) ongoing stormwater compliance inspections for the Sobrato project, working closely with the
project lead and QSD to continuously update and ensure the site was in compliance with the ongoing requirements. This site was
generally quite clean and continued to provide ongoing BMP maintenance. There was one verbal notice to remove litter, but otherwise
the site was consistently clean as they finalized this project.
2) The City also conducted inspections for the Bay Road utilities undergrounding project, a Capital Improvement Project for the City, which
required dewatering in soil that is known to be contaminated with various pollutants. This site received three illicit discharges, due to three
separate incidents of discharge of dewatering material onto a private property. This project was subject to fines and penalties associated
with the violations.
FY 2016-2017 Annual Report C.6 – Construction Site Controls
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 6-2 9/30/17
C.6.e.iii.(3)(e) ► Construction Related Storm Water Enforcement
Actions
Enforcement Action
(as listed in ERP)53
Number Enforcement Actions Issued
Level 154 Verbal Warning / Written Notice/Minor Violation—Return to Compliance
1
Level 2 Warning Notice or Administrative Action or Stop Work Notice 1
Level 3 Administrative Action with Penalty and/or Cost Recovery 2
Level 4 Legal Action
0
Total 4
C.6.e.iii.(3)(f) ► Illicit Discharges
Number
Number of illicit discharges, actual and those inferred through evidence at hillside sites, high priority sites and sites that
disturb 1 acre or more of land (C.6.e.iii.(3)(f))
3
C.6.e.iii.(3)(g) ► Corrective Actions
Indicate your reporting methodology below.
X Permittee reports multiple discrete potential and actual discharges as one enforcement action.
Permittee reports the total number of discrete potential and actual discharges on each site.
Number
Enforcement actions or discrete potential and actual discharges fully corrected within 10 business days after
violations are discovered or otherwise considered corrected in a timely period (C.6.e.iii.(3)(g)).
3
Total number of enforcement actions or discrete potential and actual discharges for the reporting year 3
Comments:
All matters were resolved within a timely manner.
53Agencies should list the specific enforcement actions as defined in their ERPs. 54For example, Enforcement Level 1 may be Verbal Warning.
FY 2016-2017 Annual Report C.6 – Construction Site Controls
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 6-3 9/30/17
C.6.e.iii.(4) ► Evaluation of Inspection Data
Describe your evaluation of the tracking data and data summaries and provide information on the evaluation results (e.g., data trends, typical
BMP performance issues, comparisons to previous years, etc.).
Description: The City has a team that is willing and trained to escalate enforcement, even for our own contractors, to prevent that pollution will
enter the local waterways or be discharged onto private property. Due to the intensity of contamination in certain areas of the City, there is a
higher scrutiny on the potential for pollution, and staff is keeping their observations to a peak when a construction project is underway. The City is
finding that contractors that regularly work in the Bay Area are found to be more readily in compliance than contractors that are not from the Bay
Area and may not be as familiar with BMP practices, and do not understand why it is not allowed to dewater onto property of their preference.
C.6.e.iii.(4) ► Evaluation of Inspection Program Effectiveness
Describe what appear to be your program’s strengths and weaknesses, and identify needed improvements, including education and outreach.
Description:
In FY 16/17, East Palo Alto 1) revised operating procedures and provided training to inspectors; 2) ensured all construction inspectors and Code
Enforcement Officers received National SWPPP Training; 3) participated in the SMCWPPP New Development Subcommittee.
C.6.f.iii. ► Staff Training Summary
Training Name Training Dates Topics Covered
No. of Inspectors
in Attendance
SMCWPPP Construction Stormwater Inspector
Training
2/1/2017 Construction inspections, BMPs, SWTMs Installation 2
National SWPPP Training 3/8/2016 SWPPP Training for Construction General Permit 5
Ongoing Inspections Monthly Internal training at inspection site/construction 2
FY 2016-2017 Annual Report C.7 – Public Information and Outreach
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 7-1 9/30/17
Section 7 – Provision C.7. Public Information and Outreach
C.7.b.i.(1) ► Outreach Campaign
Summarize outreach campaign. Include details such as messages, creative developed, and outreach media used. The detailed outreach
campaign report may be included as an attachment. If outreach campaign is being done by participation in a countywide or regional program,
refer to the separate countywide or regional Annual Report.
Summary:
See Section 7 and Section 9 of the SMCWPPP FY 16-17 Annual Report for a description of activities conducted at Countywide level.
C.7.c. ► Stormwater Pollution Prevention Education
No Change.
FY 2016-2017 Annual Report C.7 – Public Information and Outreach
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 7-2 9/30/17
C.7.d. ► Public Outreach and Citizen Involvement Events
Describe general approach to event selection. Provide a list of outreach materials and giveaways distributed.
Use the following table for reporting and evaluating public outreach events
See the C.7 Public Outreach and Citizen Involvement Events section of SMCWPPP FY 16-17 Annual Report for a summary of activities.
Event Details Description (messages, audience) Evaluation of Effectiveness
Earth Day About 8 dozen people participated in Earth Day,
learning about the watershed, and potential
pollutants. The Mayor provided and overview of
topics that residents can conduct to ensure that
the waterways are clean. The event was located
at Cooley Landing, a Bayfront park.
The program was a success because many residents
raved about the event which also included a local
band. The amount of materials that were taken
included less toxic household cleaning products, and
OWOW outreach about cockroaches and ants, which
were popular with guests.
Clean Zones An average of 20-30 residents continue to
converge each month to an area of their
choosing to clean up the City by removing litter
in areas identified by the community as heavily
polluted. This monthly activity is managed
through the Police Department through a local
grant. Local organizations can earn a stipend for
participation, which is usally between $150-$300,
depending on the size of the group. These funds
can be used at the group’s discretion. During
these Clean Zone events, residents are provided
with outreach about solid waste service and
educated about illegal dumping of household
materials and litter.
This program is quite effective, and gaining in
popularity. The City’s goal is that there will be more
publicity for this program because it is so effective at
educating and engaging the community. Publication
of this information has been luke-warm due to unsure
funding. The City hopes to have a secure funding
source to provide these monthly cleanup stipends in
the future. Residents distribute information about
appropriate solid waste disposal, information about
healthy alternatives to chemicals including cleaning
products and pest management. All age groups are
welcome and these events tend to attract ages
8months to 80 years old.
FY 2016-2017 Annual Report C.7 – Public Information and Outreach
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 7-3 9/30/17
C.7.e. ► Watershed Stewardship Collaborative Efforts
Summarize watershed stewardship collaborative efforts and/or refer to a regional report that provides details. Describe the level of effort and
support given (e.g., funding only, active participation etc.). State efforts undertaken and the results of these efforts. If this activity is done regionally
refer to a regional report.
Evaluate effectiveness by describing the following:
Efforts undertaken
Major accomplishments
Summary:
See the C.7 Watershed Stewardship Collaborative Efforts section of SMCWPPP FY 16-17 Annual Report for a summary of activities.
C.7.f. ► School-Age Children Outreach
Summarize school-age children outreach programs implemented. A detailed report may be included as an attachment.
Use the following table for reporting school-age children outreach efforts.
See the C.7 School-Age Children Outreach section of SMCWPPP FY 16-17 Annual Report for a summary of activities.
The following activities all occurred at the City’s environmental education center: Cooley Landing located at 2100 Bay Road surrounded by SF Bay.
Program Details Focus & Short Description
Number of
Students/Teachers
reached Evaluation of Effectiveness
Provide the following
information:
Name Grassroots Ecology
Grade or level (elementary/
middle/ high) 3-5
Brief description, messages, methods of
outreach used
Message is about watershed health,
including native plantings,
biology/microscope use of local water
observations, art, etc.
200+annually Staff indicate this is a wildly popular program that
allows for field trips and after school and weekend
cleanup events according to funding. The City is
considering a joint agreement with this non-profit to
continue and expand existing programs.
Provide the following
information:
Name Linda Gass
Grade or level (elementary/
middle/ high) all ages
Outreach about the original Bay shoreline,
native plants, and cleanup activities as
needed to plant vegetation along the
estimated original San Francisco Bay
shoreline, prior to infill.
200+annually Staff indicate this was a wildly popular program that
allows activities for people who are artistically
inclined, as well as naturalists. Provided a venue to
enable residents to understand this historical space
at Cooley Landing.
Provide the following Brief description, messages, methods of 200+annually Staff indicate this was a wildly popular program that
FY 2016-2017 Annual Report C.7 – Public Information and Outreach
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 7-4 9/30/17
information:
Name City of Palo Alto
Grade or level (elementary/
middle/ high) 3-5
outreach used
Message is about watershed health,
including native plantings,
biology/microscope use of local water
observations, art, etc.
allows for field trips and after school and weekend
educational events according to funding. The City
of Palo Alto was using the City’s education center
for a short time and provided environmental
stewardship activities according to an agreement
for facility use.
FY 2016-2017 Annual Report C.9 – Pesticides Toxicity Controls
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 9-1 9/30/17
Section 9 – Provision C.9 Pesticides Toxicity Controls
C.9.a. ► Implement IPM Policy or Ordinance
Is your municipality implementing its IPM Policy/Ordinance and Standard Operating Procedures? X Yes No
If no, explain:
Report implementation of IPM BMPs by showing trends in quantities and types of pesticides used, and suggest reasons for increases in use of
pesticides that threaten water quality, specifically organophosphates, pyrethroids, carbamates fipronil, indoxacarb, diuron, and diamides. A
separate report can be attached as evidence of your implementation.
Trends in Quantities and Types of Pesticide Active Ingredients Used55
Pesticide Category and Specific Pesticide Active Ingredient
Used
Amount56
FY 15-16 FY 16-17 FY 17-18 FY 18-19 FY 19-20 FY 20-21
Organophosphates None None
Active Ingredient Chlorpyrifos None None
Active Ingredient Diazinon None None
Active Ingredient Malathion None None
Pyrethroids (see footnote #57 for list of active ingredients) None None
Active Ingredient TypeX None None
Active Ingredient Type Y None None
Carbamates None None
Active Ingredient Carbaryl None None
Active Ingredient Aldicarb None None
Fipronil None None
Indoxacarb Reporting not
required in FY
15-16
None
55Includes all municipal structural and landscape pesticide usage by employees and contractors. 56Weight or volume of the active ingredient, using same units for the product each year. Please specify units used. The active ingredients in any pesticide are listed on
the label. The list of active ingredients that need to be reported in the pyrethroids class includes: metofluthrin, bifenthrin, cyfluthrin, beta-cyfluthrin, cypermethrin,
deltamethrin, esfenvalerate, lambdacyhalothrin, and permethrin.
FY 2016-2017 Annual Report C.9 – Pesticides Toxicity Controls
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 9-2 9/30/17
Diuron Reporting
not required
in FY 15-16
None
Diamides Reporting
not required
in FY 15-16
None
Active Ingredient Chlorantraniliprole None
Active Ingredient Cyantraniliprole None
The City has started to implement the following IPM Tactics and Strategies beginning FY 16/17:
Use of non-chemical strategies such as monitoring, mowing weeds, mulching.
Removal of plants that require frequent pesticide applications.
Replacing invasive plants with natives.
Preventive actions such as sealing holes and gaps in structures, improving sanitation.
Use of baits and traps instead of broadcast pesticides
Use Roundup ProMax (Glycophosphate) as a last resort pesticide.
C.9.b. ► Train Municipal Employees
Enter the number of employees that applied or used pesticides (including herbicides) within the scope of their duties this reporting
year. 7
Enter the number of these employees who received training on your IPM policy and IPM standard operating procedures within this
reporting year. 7
Enter the percentage of municipal employees who apply pesticides who have received training in the IPM policy and IPM standard
operating procedures within this reporting year. 3
Type of Training:
SMCWPPP Landscape IPM Training held on March 8, 2017, PAPA Seminar, and local tailgate training
FY 2016-2017 Annual Report C.9 – Pesticides Toxicity Controls
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 9-3 9/30/17
C.9.c. ► Require Contractors to Implement IPM Did your municipality contract with any pesticide service provider in the reporting year, for either
landscaping or structural pest control? X Yes No
If yes, did your municipality evaluate the contractor’s list of pesticides and amounts of active ingredients
used? X Yes No,
If your municipality contracted with any pesticide service provider, briefly describe how contractor compliance with IPM Policy/Ordinance and
SOPs was monitored
Simply following the above efforts of updating the IPM contract, requesting and reviewing the active ingredients and quantities of pesticides applied has resulted in
the contractor reducing the amount of pesticide and finding alternative means of eliminating pests with controls that are not listed as hazardous.
C.9.d. ► Interface with County Agricultural Commissioners
Did your municipality communicate with the County Agricultural Commissioner to: (a) get input and assistance on
urban pest management practices and use of pesticides or (b) inform them of water quality issues related to
pesticides? X
Yes
No
If yes, summarize the communication. If no, explain.
See Section 9 of the SMCWPPP FY 16-17 Annual Report for summary of communication with the San Mateo County Agricultural Commissioner. The City reports directly
to County Ag and must receive ongoing regulation for any applications, including Roundup Pro Max.
Did your municipality report any observed or citizen-reported violations of pesticide regulations (e.g., illegal handling
and applications of pesticides) associated with stormwater management, particularly the California Department of
Pesticide Regulation (DPR) surface water protection regulations for outdoor, nonagricultural use of pyrethroid
pesticides by any person performing pest control for hire?
X
Yes
No
If yes, provide a summary of improper pesticide usage reported to the County Agricultural Commissioner and follow-up actions taken to correct
any violations. A separate report can be attached as your summary.
The City received a report that pest controls were being applied without proper notification to residents. This incident was referred to SMC Ag. Commissioner for
follow-up and investigation. An investigation ensued and resulted in ongoing caution with this applicator, wherein the owner who contracted with this company
subsequently changed companies to utilize IPM controls instead.
C.9.e.ii.(1) ► Public Outreach: Point of Purchase
Provide a summary of public outreach at point of purchase, and any measurable awareness and behavior changes resulting from outreach (here
or in a separate report); OR reference a report of a regional effort for public outreach in which your agency participates.
Summary:
See the C.9 Pesticides Toxicity Control section of the SMCWPPP FY 16-17 Annual Report for information on point of purchase public outreach conducted countywide
and regionally.
FY 2016-2017 Annual Report C.9 – Pesticides Toxicity Controls
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 9-4 9/30/17
C.9.e.ii.(2) ► Public Outreach: Pest Control Contracting Outreach Provide a summary of outreach to residents who use or contract for structural pest control and landscape professionals); AND/OR reference a
report of a regional effort for outreach to residents who hire pest control and landscape professionals in which your agency participates.
Summary:
See the C.9 Pesticides Toxicity Control section of the SMCWPPP FY 16-17 Annual Report for a summary of public outreach to residents who hire pest control and
landscape professionals.
C.9.e.ii.(3) ► Public Outreach: Pest Control Operators
Provide a summary of public outreach to pest control operators and landscapers and reduced pesticide use (here or in a separate report);
AND/OR reference a report of a regional effort for outreach to pest control operators and landscapers in which your agency participates.
Summary:
See the C.9 Pesticides Toxicity Control section of SMCWPPP FY 16-17 Annual Report for a summary of outreach to pest control operators and landscapers to reduce
pesticide use.
C.9.f. ► Track and Participate in Relevant Regulatory Processes
Summarize participation efforts, information submitted, and how regulatory actions were affected; AND/OR reference a regional report that
summarizes regional participation efforts, information submitted, and how regulatory actions were affected.
Summary:
During FY 16-17, we participated in regulatory processes related to pesticides through contributions to the Program, BASMAA and CASQA. For additional information,
see the Regional Report submitted by BASMAA on behalf of all MRP Permittees.
FY 2016-2017 Annual Report C.10 – Provision C.10 Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-1 9/30/17
Section 10 - Provision C.10 Trash Load Reduction
57 See Appendix 10-1 for changes between 2009 and FY 16-17 in trash generation by TMA as a result of Full Capture Systems and Other Measures.
C.10.a.i ► Trash Load Reduction Summary
For population-based Permittees, provide the overall trash reduction percentage achieved to-date within the jurisdictional area of your
municipality that generates problematic trash levels (i.e., Very High, High or Moderate trash generation). Base the reduction percentage on the
information presented in C.10.b i-iv and C.10.e.i-ii. Provide a discussion of the calculation used to produce the reduction percentage, including
whether the 70% mandatory trash load reduction deadline was attained. If not attained, attach and include reference to a Plan to comply with
the deadline in a timely manner, which should include the Permittee’s plan and schedule to install full capture systems/devices.
Trash Load Reductions
Percent Trash Reduction in All Trash Management Areas (TMAs) due to Trash Full Capture Systems (as reported C.10.b.i) 4.4%
Percent Trash Reduction in all TMAs due to Control Measures Other than Trash Full Capture Systems (as reported in C.10.b.ii)57
35.3%
Percent Trash Reduction due to Jurisdictional-wide Source Control Actions (as reported in C.10.b.iv)1 10.0%
SubTotal for Above Actions 49.7%
Trash Offsets (Optional)
Offset Associated with Additional Creek and Shoreline Cleanups (as reported in C.10.e.i) 10%
Offset Associated with Direct Trash Discharges (as reported in C.10.e.ii) 0%
Total (Jurisdictional-wide) % Trash Load Reduction in FY 16-17 59.7%
Discussion of Trash Load Reduction Calculation and Attainment of the 70% Mandatory Deadline:
The City reported a 29% trash load reduction in its FY 15-16 Annual Report. Because the City did not achieve the non-mandatory performance guideline of 60% by
July 1, 2016, a Trash Action Plan was prepared and submitted to the Water Board to document the description and schedule of additional trash load reduction
control actions that would be implemented to attain and exceed the required 70% percent reduction by July 1, 2017. During FY 16-17, the City began implementing
the action plan and increased its load reduction to 50%. Descriptions of the actions taken to-date to reduce trash in the City are summarized in this section of the
annual report. Methods used to calculate the reduction are consistent with the methods described in the MRP.
Consistent with MRP provision C.10.f.v.b, the City has attached a report in that section of this annual report, which describes actions to comply with the mandatory
reduction deadlines in a timely manner. The report includes a plan and schedule for implementation of full capture systems sufficient to attain the required 70%
reduction.
FY 2016-2017 Annual Report C.10 – Provision C.10 Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-2 9/30/17
C.10.a.iii ► Mandatory Trash Full Capture Systems
Provide the following:
1) Total number and types of full capture systems (publicly and privately-owned) installed prior to FY 16-17, during FY 16-17, and to-date,
including inlet-based and large flow-through or end-of-pipe systems, and qualifying low impact development (LID) required by permit
provision C.3.
2) Total land area (acres) treated by full capture systems for population-based Permittees and total number of systems for non-population
based Permittees compared to the total required by the permit.
Type of System # of Systems Areas Treated
(Acres)
Installed Prior to FY 16-17
Connector Pipe Screens (Public) 38 55.6
Installed in FY 16-17
None NA NA
Total for all Systems Installed To-date 38 55.6
Treatment Acreage Required by Permit (Population-based Permittees) 18
Total # of Systems Required by Permit (Non-population-based Permittees) N/A
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-3 9/30/17
C.10.b.i ► Trash Reduction - Full Capture Systems
Provide the following:
1) Jurisdictional-wide trash reduction in FY 16-17 attributable to trash full capture systems implemented in each TMA;
2) The total number of full capture systems installed to-date in your jurisdiction;
3) The percentage of systems in FY 16-17 that exhibited significant plugged/blinded screens or were >50% full when inspected or maintained;
4) A narrative summary of any maintenance issues and the corrective actions taken to avoid future full capture system performance issues;
and
5) A certification that each full capture system is operated and maintained to meet the full capture system requirements in the permit.
TMA Jurisdiction-wide
Reduction (%)
Total # of Full
Capture
Systems
% of Systems Exhibiting
Plugged/Blinded Screens
or >50% full in FY 16-17
Summary of Maintenance Issues and Corrective Actions
1 4.4%
38 29% Grit, Dirt, single use food containers, residential trash,
2 0.0%
3 0.0%
4 0.0%
5 0.0%
6 0.0%
7 0.0%
8 0.0%
Total 4.4%
Certification Statement:
The City of East Palo Alto certifies that a full capture system maintenance and operation program is currently being implemented to maintain the full trash capture
screens in manner that meets the full capture system requirements included in the Permit.
C.10.b.i ► Trash Reduction - Full Capture Systems
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-4 9/30/17
C.10.b.ii ► Trash Reduction – Other Trash Management Actions (PART A)
Provide a summary of trash control actions other than full capture systems or jurisdictional source controls that were implemented within each TMA,
including the types of actions, levels and areal extent of implementation, and whether actions are new, including initiation date.
TMA Summary of Trash Control Actions Other than Full Capture Systems
1A
These areas are treated with small full trash capture devices in inlets, Connector Pipe Screens, which are cleaned twice a year and when the
devices are more than 50% full. Future efforts are likely to remove the small full trash capture devices in lieu of installing a large scale device at the
end of the O’Connor Watershed, which serves this TMA, along with about 70% of the City’s watershed.
1B
This trash management area has received enhanced trash capture effort due to the intensity of trash in this area, Enhanced street sweeping efforts,
community cleanups, intensive enforcement for solid waste management, and careful audits of the street sweeping efforts. This TMA had existing
street sweeping parking enforcement signage with increased effectiveness with enhanced parking enforcement (new enforcement staff was hired).
1C
This trash management area has received enhanced trash capture effort due to the intensity of trash in this area, Enhanced street sweeping efforts,
community cleanups, intensive enforcement for solid waste management, and careful audits of the street sweeping efforts. This TMA did not have
existing street sweeping parking enforcement signage; this signage was installed in FY 15/16 but vehicles did not adhere to the new enforcement
signage. As such, increased effectiveness was provided with enhanced parking enforcement (new enforcement staff was hired). With this, streets are
much cleaner.
1D
This trash management area has received enhanced trash capture effort due to the intensity of trash in this area, Enhanced street sweeping efforts,
community cleanups, intensive enforcement for solid waste management, and careful audits of the street sweeping efforts. This TMA did not have
existing street sweeping parking enforcement signage; this signage was installed in FY 15/16 but vehicles did not adhere to the new enforcement
signage. As such, increased effectiveness was provided with enhanced parking enforcement (new enforcement staff was hired). With this, streets are
much cleaner. There is one street in this TMA which has become (in FY 16/17) a parking area for RVs where people are living. Solid waste is piling up
on the street, and human waste is becoming a possible public health issue.
2
This TMA does not currently have street sweeping signage to restrict parking during street sweeping hours. This will be a future effort for stormwater
enhancements. Community cleanups, intensive enforcement for solid waste management, and careful audits of the street sweeping efforts have
been enhancements to the program in this area.
3
This TMA represents a Retail area. Efforts have been made to work directly with retailers to address appropriate solid waste management, including
litter, associated with the parking areas, solid waste bin management, and enhanced trash and recycling bins. This has included intensive
enforcement for solid waste management with fines and penalties for noncompliance.
4
This TMA refers to schools. Efforts are being made for school aged students to participate in litter abatement efforts for volunteer programs and field
trips to Cooley Landing, and Coastal Clean and National Rivers Cleanup Days, summer programs, Community cleanup efforts through the Clean
Zone activities, and ongoing community cleanup efforts organized or supported by the City.
5A and 5B
This trash management area has received enhanced trash capture effort due to the intensity of trash in this area, Enhanced street sweeping efforts,
community cleanups, intensive enforcement for solid waste management, and careful audits of the street sweeping efforts. This TMA had existing
street sweeping parking enforcement signage with increased effectiveness with enhanced parking enforcement (new enforcement staff was hired).
6
This trash management area has received enhanced trash capture effort due to the intensity of trash in this area, Enhanced street sweeping efforts,
community cleanups, intensive enforcement for solid waste management, and careful audits of the street sweeping efforts. This TMA had existing
street sweeping parking enforcement signage with increased effectiveness with enhanced parking enforcement (new enforcement staff was hired).
7 This trash management area has received enhanced trash capture effort due to the addressing homeless encampments, RVs and oversized vehicle
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-5 9/30/17
parking in this area. Private property cleanups, intensive enforcement for solid waste management, and structural controls of the sites to ensure
isolated areas are not accessible to the public has resulted in substantial compliance and eliminated many tons of materials formerly distributed
directly into the San Francisco Bay.
8*
This TMA represents the parks and open space of the City, which the City has provide enhanced trash capture through installation of “No Camping”
signage in the public right of way, along with abating litter through staff pick-up of litter, along with community cleanups throughout the year.
Further, requiring parties to address litter as a condition of the permit issuance.
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-6 9/30/17
Summary of Trash Control Measures Other than Full Capture Devices:
On-land Cleanup: Beginning in August 2012, the City began the “Partnership in Pride campaign” in an effort to engage community members to take more
pride in the blight throughout the City, with a focus on litter and graffiti. Beginning with a high school football team building exercise, the Campaign provided
an opportunity for many students to earn their
Partial Capture Devices: The City of East Palo Alto installed a fence/banister/flood control wall along the San Francisquito Creek which has provided a
substantial reduction in directly deposited litter and trash, which has subsequently preventing hundreds of gallons of trash from entering the waterways by
restricting direct access into the San Francisquito Creek. While this was not the primary function of this flood control wall, it has reduced the trash load at the
City’s trash hot spot tremendously and has also provided enhanced understanding of the amount of litter entering the San Francisquito Creek via stormdrain
outfalls from City Streets.
Storm Drain Inlet Cleaning: When the City incorporated, the stormdrain system was poorly maintained. Since the MRP 1.0, the City has been maintaining all
stormdrain inlets with the Maintenance Staff under the Public Works Division. Materials are removed with a vactor truck twice a year to ensure the inlets are
not prone to flooding.
In FY 13/14, the City had a stormdrain assessment conducted to determine the functionality of the stormdrain system as well as the areas throughout the
stormdrain system that require enhanced debris removal due to areas of damaged infrastructure. The Stormdrain Master Plan was prepared and is being
implemented to ensure incremental improvement throughout the stormdrain system.
During FY 15/16, the City has moved forward with the acquisition of a new vactor truck as the prior device was becoming a maintenance burden. During FY
16/17 the City will have a new machine that will enable the City to more accurately track the stormdrain inlets that have been maintained through electronic
reporting equipment.
During FY 15/16, the City has conducted a full assessment of the O’Connor Pump Station to not only remove trash that accumulates in the 2’ trash racks, but to
also remove the accumulated sediment that has accumulated since—at a minimum—the City’s incorporation in 1983. The vault/holding bay had areas of
over five feet of accumulated sediment deposited inside. All of this material was removed to ensure full capacity of the pump station.
During FY 16/17, the City regularly cleaned inlet devices and expanded cleanout to include stormdrain manholes, where identified as heavily impacted with
sediment and other materials through the recent Stormdrain Master Plan. Materials removed were dewatered and settled a bin with effluent sent to the
sanitary district for appropriate treatment (without solids).
Uncovered Loads: During MRP 1.0, the City attempted a variety of efforts to reduce uncovered loads. Due to the large number of self-hauling businesses, local
efforts have been constrained by varying staffing levels and the prioritization . In FY 14/15 and 15/16, the City began hiring community service aids to provide
parking enforcement. In FY 16/17, the City expanded the effort of addressing uncovered loads by working with local businesses and parking enforcement to
ensure all loads are properly covered. Fiscal Year 17/18 will expand this effort to begin fines and penalties when specific vehicles are not addressing the issue.
Anti-littering and illegal dumping enforcement activities: During the term of MRP 1.0, the City has worked on a number of fronts to address illegal dumping and
littering. Illegal dumping is tracked by complaint via a single contact point—the Maintenance Division’s receptionist—who takes each call and tracks it via
spreadsheet, sends a copy to the City’s franchise hauler, Recology, who picks up the materials within 24 hours. The City Council has received annual updates
regarding the cost of this service to the community, close to $100,000. The City has attempted to hold those accountable when the illegal dumping has
personal identification, however, unless there are photos or videos that indicate the person who actually deposited the materials, no prosecution is possible.
To date, the City has not had any successful prosecutions of illegal dumping.
The problem is on the rise. In 2014/15, there were over 700 cases of reported illegal dumping. During FY 15/16, there were over 1,000 reports of illegal dumping.
This information is tracked through Recology, who provides reports to the City as part of the Franchise Agreement.
Anti-littering has also been a focus for the community during the MRP 1.0 permit term. Primary activities have focused on providing clean-up events,
encouraging volunteer engagement, and providing classroom education on the issue of illegal dumping and littering at the 3rd and 5th grades and high
school level. While these activities have educated students, which are evident via survey of young people walking on local streets, the incidence of littering
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-7 9/30/17
has not been suppressed enough by this activity to see the substantial litter reductions necessary to meet current litter reduction future targets, as indicated
during recent annual assessments.
During FY16/17, the City has prepared a Solid Waste Management Program, with City Council support, which includes a Clean City Plan to address activities
associated with illegal dumping and illicit discharge. It is anticipated that this expanded program, which will include new part time staff members, will begin
to address the source of many illegal dumping issues: tenants and businesses who lack access to adequate trash service.
Improved Trash Bin/Container Management: During the permit term for MRP 1.0, the City has continuously revised our solid waste service, working in
conjunction with Rethink waste and Recology, our franchise hauler. Working in coordination with the commercial and residential sectors, the City assisted in
targeted audits of solid waste services and provided inspections for stormwater compliance which would reveal if the amount of trash service is appropriate
and adequate. In cases when bin capacity is less than necessary, upsized service is required.
During FY16/17, the City has prepared a Solid Waste Management Program, with City Council support, which includes a Clean City Plan to address activities
associated container management. It is anticipated that this expanded program, which will include new part time staff members, will begin to address the
source of many overflowing bin issues: tenants and businesses who lack access to adequate trash service. It is anticipated that in FY 17/18, access to
adequate sized bins will greatly reduce the quantity of trash that makes its way to the local streets and waterways.
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-8 9/30/17
C.10.b.ii ► Trash Reduction – Other Trash Management Actions (PART B)
Provide the following:
1) A summary of the on-land visual assessments in each TMA (or control measure area), including the street miles or acres available for
assessment (i.e., those associated with VH, H, or M trash generation areas not treated by full capture systems), the street miles or acres
assessed, the % of available street miles or acres assessed, and the average number of assessments conducted per site within the TMA; and
2) Percent jurisdictional-wide trash reduction in FY 16-17 attributable to trash management actions other than full capture systems implemented
in each TMA.
TMA ID
or (as applicable)
Control Measure Area
Total Street Miles58
or
Acres Available for
Assessment
Summary of On-land Visual Assessments59
Jurisdictional-wide
Reduction (%) Street Miles or Acres
Assessed
% of Applicable Street
Miles or Acres
Assessed
Average # of
Assessments Conducted
at Each Site60
1 13.06 1.77 13.56% 6.3 19.4%
2 7.92 1.04 13.15% 3.0 6.5%
3 0.78 0.39 49.86% 2.0 4.7%
4 0.94 0.20 21.85% 3.0 0.0%
5 4.36 0.60 13.83% 2.7 2.1%
6 3.13 0.36 11.56% 2.0 1.9%
7 0.79 0.38 47.41% 3.0 0.7%
8* 0.00 NA NA NA NA
Total 4.75 - - 35.3%
*TMA 8 is comprised entirely of low trash generating areas.
58 Linear feet are defined as the street length and do not include street median curbs. 59 Assessments conducted between July 2015 and July 2017 are assumed to be representative of trash levels in FY 16-17 and were therefore used to calculate the
jurisdictional-wide reductions reported in this section. 60 Each assessment site is roughly 1,000 feet in length.
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-9 9/30/17
C.10.b.iv ► Trash Reduction – Source Controls
Provide a description of each jurisdictional-wide trash source control action implemented to-date. For each control action, identify the trash reduction
evaluation method(s) used to demonstrate on-going reductions, summarize the results of the evaluation(s), and estimate the associated reduction of
trash within your jurisdictional area. Note: There is a maximum of 10% total credit for source controls.
Source
Control
Action
Summary Description &
Dominant Trash Sources
and Types Targeted
Evaluation/Enforcement Method(s)
Summary of
Evaluation/Enforcement
Results To-date
%
Reduction
Total
Reduction
Credit (%)
Single Use
Bag
Ordinance
The City Council
adopted the San
Mateo County
Reusable Bag
Ordinance on
April 19, 2012 for
implementation
October 1, 2012.
This prohibits the
distribution of
single-use
plastic bags and
requires a $0.10
fee be assessed
for paper or
heavy plastic
bags.
Inspections and hot spot assessments are conducted to assess the
effectiveness of the control measure in reducing trash from
entering the municipal stormwater conveyance system. The City
developed its
% trash reduced estimate using the following assumptions:
1.) Single use plastic bags comprise 8% of the trash discharged
from stormwater conveyances, based on the Regional Trash
Generation Study conducted by BASMAA;
95% of single use plastic bags distributed in the City/County are
affected by the implementation of the ordinance, based on the
County of San Mateo’s Environmental Impact Report; and
Of the bags affected by the ordinance, there are now 90% less bags
being distributed, based on customer complaints received by the
County of San Mateo’s Department of Environmental Health Services.
This is conservative estimate given that in FY 13-14 Environmental
Services only received complaints about 4, of the over 1900
businesses in San Mateo County that are affected by the single-use
plastic bag ordinances, and the fact that staff inspections have
indicated no violations of this ordinance.
Results of assessments
conducted by the County
of San Mateo on behalf of
all municipalities in San
Mateo County indicate
that the City’s ordinance
is effective in reducing
the number of single use
plastic bags in stormwater
discharges. This
preliminary conclusion is
based on the very small
number of complaints
received from customers
about businesses in San
Mateo County that are
continuing to use single
use plastic bags after
ordinances were
adopted.
7%
10.0%
(Maximum)
Expanded
Polystyrene
Food
Service
Ware
Ordinance
No such ban No such ban No such ban No
suc
h
ba
n
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-10 9/30/17
C.10.c ► Trash Hot Spot Cleanups
Provide the FY 16-17 cleanup date and volume of trash removed during each MRP-required Trash Hot Spot cleanup during each fiscal year listed.
Indicate whether the site was a new site in FY 16-17.
Trash Hot Spot
New Site in
FY 16-17
(Y/N)
FY 16-17 Cleanup
Date(s)
Volume of Trash Removed (cubic yards)
FY 2012-13 FY 2013-14 FY 2014-15 FY 2015-16 FY 2016-17
EPA01 N 05/20 /2017
09/17/2016 1.6 3.6 2.4 0.6 0.1
EPA02 YES 05/20 /2017
09/17/2016 n/a N/a n/a n/a 1.5
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-11 9/30/17
C.10.d ►Long-Term Trash Load Reduction Plan
Provide descriptions of significant revisions made to your Long-term Trash Load Reduction Plan submitted to the Water Board in February 2014.
Describe significant changes made to primary or secondary trash management areas (TMA), baseline trash generation maps, control measures, or
time schedules identified in your plan. Indicate whether your baseline trash generation map was revised and if so what information was collected
to support the revision. If your baseline trash generation map was revised, attach it to your Annual Report.
Description of Significant Revision Associated
TMA
In FY 15-16, consistent with all MRP Permittees, all public K-12 schools, college and university parcels were made non-jurisdictional
on the City’s baseline trash generation maps. Under California Government Code Sections 4450 through 4461, the construction,
modification, or alternation of facilities and/or structures on these parcels are under the jurisdiction of the California Division of
State Architect and not the City. The public right-of-way (e.g., streets and sidewalks) surrounding these parcels remain as
jurisdictional on the City’s baseline trash generation maps. The City’s revised baseline trash generation map is included as
Appendix 10-2.
All applicable
During FY 16/17, the City switched out all components that were deemed “full trash capture equivalent” in exchange for full trash capture
devices. The City has been pursuing the installation large scale full trash capture devices where the lowest installation costs, lowest
maintenance requirements, and highest drainage area will be treated. The present effort includes two major outfall locations that drain roughly
70% of the City.
1A,
1C,
1D,
portions of 2,
3,
4,
5,
6, and
8
This TMA requires coordination with future developers to address the drainage as it currently flows into drainage outfalls that are submerged with
sediment and bay mud. Treatment depends on future planned development of TMA #7. 1B
This TMA will require additional work to address the full trash capture needs as the stormwater comingles in this area with the City of Menlo Park
as well as the water from the Caltrans drainage. This will require collaboration with these other jurisdictions. 2
This TMA requires coordination with future developers to address the drainage as it currently flows into drainage outfalls that are submerged with
sediment and bay mud. Treatment depends on future planned development of the Ravenswood Specific Plan area. 7
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-12 9/30/17
C.10.e. ► Trash Reduction Offsets (Optional)
Provide a summary description of each offset program implemented, the volume of trash removed, and the offset claimed in FY 16-17.
Also, for additional creek and shoreline cleanups, describe the number and frequency of cleanups conducted, and the locations and cleanup
dates. For direct discharge control programs approved by the Water Board Executive Officer, also describe the results of the assessments
conducted in receiving waters to demonstrate the effectiveness of the control program. Include an Appendix that provides the calculations
and data used to determine the trash reduction offset.
Offset Program Summary Description of Actions and Assessment Results
Volume of Trash (CY)
Removed/Controlled
in FY 16-17
Offset
(% Jurisdiction-wide
Reduction)
Additional Creek
and Shoreline
Cleanups
(Max 10% Offset)
Clean Zones: community members’ cleanup around the City to address litter problems. They
receive a stipend from the Police Department for litter control efforts. There have been
roughly 275 volunteers participating in this cleanup effort, removing roughly 20 cubic yards
year round from the city streets associated with illegal dumping of various types of litter and
encampment types of waste.
Cleanups were focused in areas noted in the description in TMA discussion.
TMA #7:
The City, working with a major land owner, managed to permanently eradicate a major
homeless encampment, through working with 1) community service agencies to provide any
of the permanent camp dwellers with options to receive needed services, 2) require through
code enforcement efforts and penalties cleanup and removal of all debris associated with
the encampments, and 3) permanently address access to the site with structural controls and
ongoing maintenance to prevent access to these isolated areas. Four years in the making,
the City worked with these individuals (there were over 40 present at the peak encampment
size), until there were 17 people living in this area year-round at the time of abatement.
The City would have requested a full assessment, however, as this was conducted by a
private entity, tracking all materials was not a luxury the City was able to utilize.
120 cubic yards
(minimum) 10%
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-13 9/30/17
C.10.e. ► Trash Reduction Offsets (Optional)
Provide a summary description of each offset program implemented, the volume of trash removed, and the offset claimed in FY 16-17.
Also, for additional creek and shoreline cleanups, describe the number and frequency of cleanups conducted, and the locations and cleanup
dates. For direct discharge control programs approved by the Water Board Executive Officer, also describe the results of the assessments
conducted in receiving waters to demonstrate the effectiveness of the control program. Include an Appendix that provides the calculations
and data used to determine the trash reduction offset.
Additional Creek
and Shoreline
Cleanups
(Max 10% Offset)
(cont’d)
Assumptions made in this calculation include: Each person generates roughly 6 pounds of
solid waste and 0.75 pounds of human waste (sewage) per day. We are estimating about
only ~5 pounds of waste per person, per day, for a total of 85 pounds of trash per day
generated from these 17 people (although visual observations tells us these individuals
brought more waste than the average person generates), all of which was readily was
distributed directly into the local waterway at the edge of this soil mound.
This is ~31,025 pounds of trash that was being readily distributed by wind and water
(including raw sewage) directly into the San Francisco Bay.
With about 175 pounds per yard, this represents about 177 cubic yards per year that have
ceased direct discharge into the San Francisco Bay.
We are taking credit for 100 cubic yards of this very conservatively estimated waste that was
eliminated.
Further, within San Francisquito Creek, about five encampments which had been fairly
permanent settlements, have been completely eliminated. We are not taking credit for this
due to the fact we’ve already taken maximum credit for this effort in this section.
Direct Trash
Discharge
Controls
(Max 15% Offset)
0
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-14 9/30/17
C.10.f.v.b As provided in the most recent update provided to Water Board Staff on April 30, 2017 and consistent with MRP provision C.10.f.v.b, the City has attached this report to
describe actions to comply with the mandatory reduction deadlines in a timely manner.
As previously noted in the FY 15/16 Annual Report and Amended Long Term Trash Load Reduction Plan, the City of East Palo Alto's previously implemented structural
controls and soft mechanisms noted in the Long Term Trash Load Reduction Plan did not result in adequate reduction to achieve 60% full trash capture equivalency
benchmarks set for June 30, 2016 . The noted inadequacy is attributed largely to unforeseen negative shifts in the effectiveness of those strategies that were
implemented by the City. The LTTLRP primarily utilized soft (full trash capture equivalency) mechanisms such as street sweeping, illegal dumping remedies , code
enforcement strategies, on-ground cleanups and the minimum required full trash capture infrastructure, for trash load reduction attainment. Over the course of
implementation, the City did see trends that suggested the approach would result in full compliance, as noted through assessments revealing reduced trash loads over
time. However, in FY 2016, the required ground-truthing assessments indicated substantial variability in the effectiveness of those strategies , with incomplete long term
effectiveness.
The City did provide the Water Board with an Updated Trash Control Measure Implementation Schedule in the 2015/2016 Annual Report submittal, which laid the
groundwork for shifting focus in the City's Amended Long Term Trash Load Reduction Plan towards utilizing full trash capture infrastructure as the primary means of
compliance with MRP 2.0 section C.10, going forward.
Since September 2016, the executive management team and City Council of East Palo Alto have created mechanisms to ensure the City is on track to preclude trash
from entering local waterways with structural means. In providing detailed steps that ensure this goal is met, our modest staff has diligently concluded the following
tasks since our 2016 Annual Report was submitted:
Amended Long Term Trash Load Reduction Plan with actions that ensure structural full trash capture is the primary tool utilized; this included Public Works and
Transportation Commission recommendation, and City Council adoption of said Plan;
Entered into a new contract with enforceable mechanisms to ensure street sweeping is effective and efficient (as a secondary compliance mechanism);
Entered into contract with CSG to conduct a full assessment of the City stormdrain system to prioritize full trash capture locations and provide a conceptual design that
meets at a minimum 70% full trash capture; finalized assessment;
Reviewed and approved a conceptual design for a large scale Full Trash Capture project that is estimated to provide a minimum of 70%, and up to 80% full trash
capture for the City, with an estimated cost of $450,000 to retrofit the City's stormdrain system with a large-scale system;
Put forth a Request for Qualifications, reviewed said proposals, and entered into contract with engineering consultants to provide assistance with design and RFP
development for concept proposal of the proposed Full Trash Capture project, assessed proposed concepts;
Received a memorandum regarding proposed full trash capture device which determined, based on hydraulic analysis of the proposed full trash capture device within
the wet well of the City’s only pump station, that the concept proposal is infeasible due to flooding potential during a model 10 year storm event; the City and
contractor will to narrow down options to prepare detailed bid and construction documents for a system at the end of the system that does not impact or exacerbate
the flooding potential of the community;
Working with the Contractor to fully assess the Runnymede drainage system for full trash capture potential with a concept design for a full trash capture device at the
outfall of the O’Connor Pump Station being further considered;
Consultant team has estimated potential construction by summer 2018 for a system which could provide up to 70% full trash capture of the City’s watershed.
Continue to detail next steps for additional full trash capture options.
Further, the City anticipates the following schedule will be set forth to obtain full MRP 2.0 compliance with section C.10 (trash) requirements in 2017:
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-15 9/30/17
March 30th: Obtain final design for O'Connor Pump Station and Runnymede Outfall retrofit and release RFP for construction, with an updated schedule for estimated
construction dates;
May 30th: Enter into contract for O'Connor Pump Station and Runnymede Outfall Full Trash Capture retrofit; obtain construction schedule with anticipated construction in
summer 2018.
As noted, this consolidated timeframe has pushed City of East Palo Alto out of compliance with MRP 2.0 provision to obtain 70% full trash capture equivalency
compliance by July 1, 2017. The revised timeframe does ensure the City will obtain structural full trash capture to meet (and likely exceed) MRP compliance targets for
70% and likely 80% full trash capture, without relying on mechanisms that have not proven effective or equivalent to full trash capture, and to ensure the City of East
Palo Alto will eliminate litter from entering local waterways en perpetuity.
Should any of the above tasks require additional permits, funding, or review, there is a high likelihood that the timeframe will be pushed out beyond Fiscal Year
2017/2018 and result in compliance being met after the summer of 2018.
The City is hopeful that the Amended Long Term Trash Load Reduction Plan and proposed schedule, noted above, will meet the Water Board's intention of obtaining full
trash capture, while ensuring the actions the City is taken are remarkably effective and efficient to address the issue of eliminating trash from entering local waterways.
The City will provide the Water Board with any updates through the upcoming efforts if the schedule should require additional revisions.
FY 2016-2017 Annual Report C.10 – Trash Load Reduction
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 10-16 9/30/17
Appendix 10-1. Baseline trash generation and areas addressed by full capture systems and other control measures in Fiscal Year 16-17.61
TMA
2009 Baseline Trash Generation
(Acres)
Trash Generation (Acres) in FY 16-17 After
Accounting for Full Capture Systems
Jurisdiction-
wide
Reduction via
Full Capture
Systems (%)
Trash Generation (Acres) in FY 16-17
After Accounting for Full Capture Systems and
Other Control Measures
Jurisdiction-
wide
Reduction via
Other Control
Measures (%)
Jurisdiction-wide
Reduction via Full
Capture AND
Other Control
Measures (%) L M H VH Total L M H VH Total L M H VH Total
1 3 20 456 0 480 54 8 418 0 480 4.4% 68 236 176 0 480 19.4% 23.8%
2 1 1 226 0 228 1 1 226 0 228 0% 1 89 136 2 228 6.5% 6.5%
3 0 0 50 0 50 0 0 50 0 50 0% 30 20 0 0 50 4.7% 4.7%
4 0 36 0 0 36 0 36 0 0 36 0% 3 12 21 0 36 0% 0%
5 0 135 28 0 162 0 135 28 0 162 0% 45 102 16 0 162 2.1% 2.1%
6 0 0 116 0 116 0 0 116 0 116 0% 0 36 76 4 116 1.9% 1.9%
7 0 102 0 0 102 0 102 0 0 102 0% 41 57 5 0 102 0.7% 0.7%
8 92 0 0 0 92 92 0 0 0 92 0% 92 0 0 0 92 0% 0%
Totals 97 294 876 0 1,267 148 282 838 0 1,267 4.4% 280 551 430 7 1,267 35.3% 39.7%
61 Numbers reported for each TMA may not exactly sum to totals due to rounding.
FY 2016-2017 Annual Report C.11 – Mercury Controls
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 11-1 9/30/17
Section 11 - Provision C.11 Mercury Controls
C.11.a. ► Implement Control Measures to Achieve Mercury Load Reductions
C.11.b. ► Assess Mercury Load Reductions from Stormwater
A summary of accomplishments for these sub-provisions are included within the C.11 Mercury Controls section of SMCWPPP’s FY 15-16 Annual Report.
C.11.c. ► Plan and Implement Green Infrastructure to Reduce Mercury Loads
If the regional or countywide mercury load reductions required by this sub-provision via Green Infrastructure by
the end of the permit term are not met, will Permittees in your county use the default population-based method
to calculate the portion of the countywide load reduction required of each Permittee? X Yes No
C.11.e. ► Implement a Risk Reduction Program
A summary of Program and regional accomplishments for this sub-provision are included in the C.11 Mercury Controls section of the Program’s FY 2016-17 Annual
Report and/or a BASMAA regional report.
FY 2016-2017 Annual Report C.12 – PCBs Controls
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 12-1 9/30/17
Section 12 - Provision C.12 PCBs Controls
C.12.a. ► Implement Control Measures to Achieve PCBs Load Reductions
C.12.b. ► Assess PCBs Load Reductions from Stormwater
See the Program’s FY 2016-17 Annual Report for:
Documentation of PCBs control measures implemented in our agency’s jurisdictional area for which load reductions will be reported and the associated management areas;
A description of how the BASMAA Interim Accounting Methodology62 was used to calculate the PCBs load reduced by each control measure implemented in our agency’s
jurisdictional area and the calculation results (i.e., the estimated PCBs load reduced by each control measure); and
Supporting data and information necessary to substantiate the load reduction estimates.
If the regional and countywide PCBs load reductions required by C.12.a are not met, will Permittees in your
county use the default population-based method to calculate the portion of the countywide load reduction
required of each Permittee? X Yes No
C.12.f. ► Manage PCB-Containing Materials and Wastes During
Building Demolition Activities So That PCBs Do Not Enter Municipal
Storm Drains
A summary of Program and regional accomplishments for this sub-provision is included in the C.12 PCBs Controls section of Program’s FY 2016-17 Annual Report
and/or a BASMAA regional report.
Does your agency plan to seek exemption from this requirement? Yes X No
62BASMAA 2017. Interim Accounting Methodology for TMDL Loads Reduced, Version 1.0. Prepared for BASMAA by Geosyntec Consultants and EOA,
Inc., September 19, 2016.
FY 2016-2017 Annual Report C.12 – PCBs Controls
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 12-2 9/30/17
C.12.g. ► Fate and Transport Study of PCBs: Urban Runoff Impact on
San Francisco Bay Margins
A summary of Program and regional accomplishments for this sub-provision are included in the C.12 PCBs Controls section of the Program’s FY 2016-17 Annual
Report and/or a BASMAA regional report.
C.12.h. ► Implement a Risk Reduction Program
A summary of Program and regional accomplishments for this sub-provision are included in the C.12 PCBs Controls section of the Program’s FY 2016-17 Annual
Report and/or a BASMAA regional report.
FY 2016-2017 Annual Report C.13 – Copper Controls
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 13-1 9/30/17
Section 13 - Provision C.13 Copper Controls
C.13.a.iii. ► Manage Waste Generated from Cleaning and
Treating of Copper Architectural Features
Provide summaries of permitting and enforcement activities to manage waste generated from cleaning and treating of copper architectural
features, including copper roofs, during construction and post-construction.
Summary:
There are no copper architectural features in EPA.
C.13.b.iii. ► Manage Discharges from Pools, Spas, and Fountains
that Contain Copper-Based Chemicals
Provide summaries of any enforcement activities related to copper-containing discharges from pools, spas, and fountains.
Summary:
There are few of these facilities in East Palo Alto with pools, spas and fountains. Such discharges are addressed by the City as illicit discharges, and all of such
discharges are required to go through the sanitary sewer when observed.
C.13.c.iii. ► Industrial Sources Copper Reduction Results
Based upon inspection activities conducted under Provision C.4, highlight copper reduction results achieved among the facilities identified as
potential users or sources of copper, facilities inspected, and BMPs addressed.
Summary:
In FY 16/17, no inspections were resulted in a reduction of copper. None of the above sources were noted for discharging
FY 2016-2017 Annual Report C.15 – Exempted and Conditionally Exempted Discharges
Permittee Name: City of East Palo Alto
FY 16-17 AR Form 15-1 9/30/17
Section 15 -Provision C.15 Exempted and Conditionally Exempted Discharges
C.15.b.vi.(2) ► Irrigation Water, Landscape Irrigation, and Lawn or
Garden Watering
Provide implementation summaries of the required BMPs to promote measures that minimize runoff and pollutant loading from excess irrigation.
Generally the categories are:
Promote conservation programs
Promote outreach for less toxic pest control and landscape management
Promote use of drought tolerant and native vegetation
Promote outreach messages to encourage appropriate watering/irrigation practices
Implement Illicit Discharge Enforcement Response Plan for ongoing, large volume landscape irrigation runoff.
Summary:
The City updated our Water Efficiency Landscape Ordinance to require all landscaping that is completed with any type of building permit requires primarily drought
tolerant landscaping and no new installation of turf unless proposed for recreational facilities. The City is among the top two Cities in the Bay Area for water
conservation, largely due to the high density and lack of commercial facilities, but also due to the price sensitivity of our customers/users. Local nursery retailers are
indicating an explosion of interest in drought tolerant plants and vegetation, though the City is only promoting through the customer service line expressing means of
reducing the cost of the water bill.
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